The Plaintiff, by undersigned counsel, and unto this Honorable Court,

most respectfully alleges that:

1. Plaintiff is of legal age, Filipino, married and a resident of

_____________, Philippines. For purposes of this action, Plaintiff
may be served with copies of our notices and orders of the
Honorable Court at the office address of the undersigned counsel
indicated below;

2. Defendant is also of legal age, Filipino, and for purposes of this

action, he may be served with summons and other processes of this
Honorable Court at his residence and post-office address at
_____________, Philippines;

3. Plaintiff is the true and registered owner of a certain parcel of land

situated in _____________, Philippines, consisting of approximately
_____________ (_____) square meters, and identified as Lot
________ and covered by Transfer Certificate of Title No.
_____________ of the Registry of Deeds of _____________;

4. That sometime in _____________, Defendant and his family began

to be in possession of the said property, not by virtue of any title or
contract, but merely upon the Plaintiff's tolerance, as he had no
immediate need of the said property at that time;

5. That on _____________, Plaintiff demanded that Defendant vacate

and return the possession of the said parcel of land to the herein
Plaintiff, but despite numerous demands for him and his family to
vacate, Defendant has remained in illegal possession of the said land
and, up to the present, still retain such possession.

6. While possession by tolerance is lawful, such possession becomes

illegal upon demand to vacate is made by the owner and the
possessor by tolerance refuses to comply with such demand (Prieto
vs. Reyes, 14 SCRA 432; Yu vs. De Lara, 6 SCRA 786, 788; Isidro vs.
Court of Appeals, G.R. No. 105586, December 15, 1993);

7. A person who occupies the land of another at the latter's tolerance

or permission, without any contract between them, is necessarily
bound by an implied promise that he will vacate upon demand (Yu
vs. De Lara, supra, cited in Sumulong vs. Court of Appeals, G.R. No.
108817, May 10, 1994);

8. That the reasonable rental value of the said land is

__________________________ (P___________) per month;
9. That due to the unjust refusal of the Defendant to vacate and to
return the said land to the Plaintiff, the latter was constrained to
endorse the said matter to its legal counsel for the filing of an
appropriate action in court for a fee of P_____________ and the
amount of P__________ per court hearing;

10.That this action is being filed within a period of one (1) year from
the demand on Defendant to vacate the said property.